Addressing Sales Practice and Conduct Risk in the Canadian Market

ADDRESSING
SALES PRACTICE
AND CONDUCT
RISK IN THE
CANADIAN
MARKET

Copyright © 2018 Accenture. All rights reserved. 2
CANADIAN BANKING SALES PRACTICE AND CONDUCT RISK
Canadian Banks are facing increased pressure to demonstrate appropriate conduct and adapt to increased regulation on suitability,
fraud and investor protection activities. Implementing a sales practice & conduct control framework and embedding ethical values
and customer centricity in a firm’s cultural DNA are critical to managing conduct risk and protecting a firm’s reputation.
Does the Organizational Culture
provide foundations for
responsible growth?
• Difficulty to articulate a strategic vision at a company level or to get the tone at the top for culture change
• Lack of clarity around roles and responsibilities to effectively drive culture change
• Insufficient mechanism to measure the level of culture adoption or to assess the effectiveness of projects in achieving adoption
• Complexity to bring all business functions together into a cross-organizational effort that touches every part of the company
• Need to navigate technology advances and proliferation of market solutions and address challenges of integrating solutions for data quality / standardization
Change Complexity
Key Challenges
Do resources have the Skills
and Capabilities to meet
emerging challenges?
Does the Sales Practices &
Conduct Risk Framework
effectively protect the firm?
• Canadian banks are facing increased pressure
from regulators (i.e. Office of the
Superintendent of Financial Institutions (OSFI),
Financial Consumer Agency of Canada) to
demonstrate appropriate banking conduct
• Shifts in customer interaction model and
information requirements are adding
additional complexity to manage
• Years of low growth places focus on new
product development and cross-selling –
creating opportunities to exploit customers
• Risk management demands a fundamentally
different workforce – able to detect
emerging risks before they impact customers
and operations
• Advances in technology, including workforce
digitalization and process automation, leading
to a re-focus on complex decision making
and data analysis requires a retraining of
resources
• In an era of volatility, changing expectations
and radical transparency, culture, ethics and
conduct is a defining issue for corporate
reputation and long-term sustainability
• Banks should move beyond an approach
governed by strict rules and regulations, to a
culture that encourages employees to think
ethically and take appropriate risk and
accountability to foster responsible growth

REPUTATIONAL & CONDUCT RISK MATURITY SCALE
Many firms continue to struggle with the prospect of managing reputation risk or have yet to begin addressing the topic
Does the Organizational Culture provide
foundations for responsible growth?

BUILDING SUSTAINABLE ORGANIZATIONAL CULTURE
In an era of volatility and radical transparency, organizational culture is becoming a defining issue for corporate reputation and long-
term sustainability. An effective strategy for organizational culture can serve to mitigate risk, and function as a differentiator and driver
of the organization’s objectives. Strong organizational culture is aligned to meet the demands of various stakeholder groups.
1
3
2
4
Risk-enabled decision making. Define processes and
governance for making challenging decisions, allowing for
intelligent risk-taking in the context of business goals and
understanding of trade-offs.
Shareholder expectations. Potentially reduce regulatory
fines and increase ROE as culture of ethical conduct
becomes normalized.
Embedded compliance. Require role-based, annual
training in key risk areas such as customer data security,
and include risk management in performance
management metrics.
Systematic testing & reporting. Institutionalize conduct
surveillance, scenario testing and reporting, allowing for
ongoing benchmarking and compliance assessments.
Business Alignment Regulatory Alignment
Employee Alignment Customer Alignment
Single view. Use analytics to understand and support
customer needs – and products – in an integrated
manner. Reinforce customer focus via product
development & review process.
Trust & reputation. Rebuild customer trust by admitting
to past challenges, soliciting input from customers and
defining the future state culture in terms of providing
value to customers.
Celebration of conduct identified. Encourage employees
to identify positive & negative conduct, celebrating integrity
and designating local conduct champions to cascade key
messages.
Attraction & retention. Recruit the right people from the
beginning, who are attracted by the opportunity to work for
a culture where conduct counts.
Business ownership. Transfer conduct controls to the
business for execution, with compliance providing
oversight.

FROM UNDERSTANDING TO ACTION: ORGANIZATIONAL CULTURE
Accenture believes that a deliberate and strategic approach to culture empowered by real-time analytics and organizational health
benchmarks can serve as the foundation for long term sustainable growth.
• A strategic approach to organizational culture and conduct can serve as foundation for a strong reputation and effective sustainability.
• Establishing strong foundations depends first on understanding the organization’s current-state culture, benchmarked against leading
research on the critical drivers of ethical behavior and decision making.
• An independent conduct culture maturity assessment takes account of policies and procedures, the perspectives of senior leaders,
performance compensation and other incentives, and the reality of day-to-day decision making as perceived by people across the
organization in order to provide a robust, evidence-based foundation for change.
• Applying tools and technology like Accenture’s Change Tracking and Ethics Analytics help remove the “black box” surrounding culture
and allow organizations to measure and monitor culture results in real-time and perform targeted interventions to support an effective
culture transformation journey.
Engage senior leaders
and identify key
requirements
Apply culture
assessment surveys
and maturity diagnostic
Assess future state
culture vision and
set priority focus
Design
sustainable culture
program
Implement
sustainable program
and track success
1 2 3 4 5
Culture Assessment Future State Design Culture Transformation
Conduct & Culture Assessment
estimated at 6 weeks
Future State Vision & Sustainable Program Design
estimated at 6 weeks
Delivery & Implementation
estimated time TBD
Organizational Culture as Foundation for Sustainability
Illustrative Approach

REPUTATIONAL & CONDUCT RISK MATURITY SCALE
Many firms continue to struggle with the prospect of managing reputation risk or have yet to begin addressing the topic
Do resources have the Skills and Capabilities to
meet emerging challenges?

REQUIRED RISK MANAGEMENT SKILLS AND CAPABILITIES
Risk management staff touches on areas such as operational task processing, compliance, complex decision making and analysis,
and technology / data management. This demands a fundamentally direct workforce with a focus on talent reskilling and recruiting.
Advisory
2020
GRC
Organization
Roles
Financial Crime
Compliance
Continuous
Monitoring and
Investigations
Risk and
Controls
Employee
Compliance
Model
Management
and Tuning
Implications of Required Skillset for the 2020 Workforce
• Increased workforce digitalization and process automation and the
creation of centers of excellence to transition Governance, Risk &
Compliance (GRC) staff from “General Risk Managers” to “Deep Subject
Matter Advisors” (SMA) that focus on solving complex problems
• GRC professionals will be able to refine specialisms (Product, Business,
Regulation) through dedicated career paths to provide more effective 1st
line of defense (LoD) oversight and advisory support
• As SMAs, GRC Officers will be expected to do more than execute
operational tasks based on information provided and should operate to
both the spirit and letter of the law, asking deeper questions to
understand context, behaviors and culture
• Staff should be savvy in leveraging the latest technology innovations for
which continuous training should be required
• While new technology may help alleviate skill shortages in selected
areas (such as Data Quality review / remediation), generally, investments
are expected to re-skill / recruit employees to best deliver in new
specialized advisory-focused roles through venues such as Accenture’s
Fordham University Alliance
Focus and Proficiency
Communications
Business Acumen
Legal Skills
Analytics
Tech. Acumen
Perf. Monitoring
Control
Oversight

Does the Sales Practices and Conduct Risk
Framework effectively protect the firm?

THE LINK BETWEEN REPUTATION AND CONDUCT
Conduct is not something firms can ignore if they want to build and protect a strong firm reputation.1 According to a survey by the
Reputation Institute, two of the top three drivers of how a firm is perceived in the market are directly related to conduct and behavior.
1.Source: 2018 Global RepTrak® 100, Reputation Institute, March 15, 2018. Access at: https://www.reputationinstitute.com/resources/pdf/2018-global-reptrak
Includes: Adapting quickly to
change, being first to market
with new products / services
and being innovative
INNOVATION
Includes: Having strong
prospects, being profitable
and exceeding financial
expectations
PERFORMANCE
Includes: Being well
organized, being excellent
managers, having a strong
and appealing leader,
having a clear vision for the
future
LEADERSHIP
Includes: Rewarding employees
fairly, being concerned for
employees’ well-being and offering
an equal opportunity workplace
WORKPLACE
Includes: Having high quality
products / services, standing
behind products / services,
having good value products /
services and meeting
customer needs
Product / Services1
Includes: Being open and
transparent, ethical and fair in
doing business
Governance2
Includes: Having a positive
influence on society, being
environmentally conscious and
supporting good causes
Citizenship3
Feeling
Trust
Admire
Governance
Esteem
12.9% 21.6%
12.5%
14.1%
15.0%
10.8%
13.1%
Drivers of Reputation
2 of the top 3 drivers
are directly related to
conduct and behavior
Methods of
Re-Enforcement
Change of Culture
Re-Prioritization of
Risk Appetite
Implementation of
Control Framework
Implementation of
Risk Management
Framework

Copyright © 2018 Accenture. All rights reserved.
10
MANAGING INCREASED REGULATORY SCRUTINY
In response to banking misconduct allegations at the major Canadian financial institutions in 2017, the Canadian regulators have
sharpened their focus on conduct culture, sales practices and product suitability governance, and how banks manage reputational
risks. We anticipate that Canadian regulators will adopt many of the US and UK conduct regulations and guidelines.
Canadian banks should look closely at the conduct
journey in the US and the UK where the conduct agenda
has matured as a concept. We anticipate that Canadian
regulators will adopt many of the US and UK conduct
regulations and guidelines.
Learning from the US & UK Experience:
Increased regulatory focus on
product / service suitability,
delivering customer-centric outcomes,
as well as monitoring employee
behavior and organizational culture.
Renewed focus on identifying and
managing conflicts of interest and
maintaining proper risk management
and control safeguards developed to
protect and reinforce a firm’s culture.
Increased scrutiny on conflicts caused
by improper sales target and
performance incentives with a focus
on personal accountability through
introduction of clawbacks, forfeiture
and other mechanisms.
Note: Illustrative list of US and UK examples.
• OSC has published the Business Conduct Requirements for registered firms
covering topics such as know your client (KYC) and suitability, marketing, client
disclosures, complaint handling, and oversight of service providers
• The OSC’s Whistleblower Program is the only Canadian program that offers
financial awards for tips that lead to successful enforcement actions. As a part of
the OSC's whistleblower policy, the regulator added to its securities regulations
anti-retaliation protections for whistleblowers
• FCAC conducting industry reviews on Consumer Protection related policies,
procedures and practices and is expected to increase enforcement actions for
customer-centric outcomes
• FCAC has placed increased scrutiny on disclosures and processes for obtaining
Customer Consent for New Products or Services and the new B-5
Consent rule outlines guidelines for making any customer communication (verbal,
written, or electronic) clear, simple and not misleading
• OSFI reviewing the domestic Retail Sales Practices at domestic
systematically important banks with a focus on risk culture, sales practices and
suitability governance and controls, and managing reputational risks
• Continued scrutiny on Performance Management and Compensation
Practices as part of OSFI’s broader probe of the components of culture and risk
following banking misconduct allegations
• OSFI also focusing on Public Disclosure and Transparency regimes that
will exert market discipline and reinforce internal risk culture with external vigilance
OSFI
FCAC
Ontario Securities
Commission
(OSC)
Financial
Conduct
Authority
Office of the
Comptroller
of the
Currency
FINRA
Accenture analysis based upon publicly available information.

REPUTATIONAL AND CONDUCT RISK FRAMEWORK
Accenture believes that protecting a firm’s ethical health and reputation requires a strong Reputational and Conduct Risk Program with
support from all areas of the bank, including executive leadership. The effort should also provide employees with the proper tools to
allow continuous improvement through monitoring and analysis.
Key ConsiderationsDetect Prevent Deter Monitor Understand
Conduct Risk Control Framework Foundational Elements
Business Model, Strategy
& Governance Roles & Accountabilities Defined Policies & Procedures Regulatory Compliance
Organizational Behavior, Conduct Culture and People Management
Defined Value Structure Compensation & Incentive
Structure Performance Management Embedded Conduct Culture
Talent Management Hiring / Staffing Training & Communications
Reinforcement
Product Design, Marketing and Sales Controls
Financial Product Design Marketing Review Product Suitability Sales Controls
Escalations
Customer Complaints Whistleblowing Programs
Data, Monitoring and Analysis
Data Management Key Metrics MI / Reporting Tools & Technology
Sources of Reputation Degradation
Business
Misconduct Internet Social Media Regulator
Scrutiny
Employee
Misconduct
Operational Incidents
& Events
Protect Against
• Strong and visible leadership commitment
required for an effective Conduct & Culture
change program
• Firms should be prepared to make operating
model changes to be customer-centric and
maintain desired behaviors
• Invest in Management Information (MI) /
analytics tools to allow the business to build
and test hypothesis for the purpose of
uncovering emerging issues and root
causes
• End-to-end solutions can support conduct
monitoring and production of MI, while
using technology to provide reminders to help
change staff and customer behavior
• Invest in programs driving a strong culture; this
starts with analyzing the firm’s current
culture, performance incentives and
controls in order to best determine how to
drive change

INTEGRATED SURVEILLANCE MONITORING
The industry is moving towards a more holistic monitoring approach to manage the dependencies between non-financial risk use cases
and empowering risk governance. Accenture has helped clients apply an integrated surveillance approach to integrate an end-to-end
workflow to collect data, distinguish the real cases, assign and monitor mitigating actions and provide dashboards / reports.
Prioritization Protocol Issue Resolution Monitoring
Assign Actions and Monitor Resolutions
Multisource Alerts or Key Risk Indicators (KRIs) (non-exhaustive)
Helps manage personal account data
breaches, gifts & entertainment
breaches, registration breaches and
affiliation issues
Provides oversight of communication
patterns with wall crossed people, as
well as social media activities
Can monitor large unhedged derivative
positions, scan for abnormal trading
patterns and examine large P&L swings
Helps reduce the risk of password
sharing, monitors password denied
patterns, and provides privileged
access
Key Performance Indicators (KPIs)can
be generated on a client satisfaction
index and help monitor complaints
KPIs can be used to monitor increased
volume of sales / spikes of dedicated
products and closures
Capital Requirements Regulation
(CRR) findings and Regulatory findings
can be monitored
Provides oversight regarding conflicts
of interests, restricted list violations,
info barrier violations and information
misuse
Data can be leveraged to address AML
issues, sanctions, corruption issues and
ongoing iinvestigations
Accenture provides in-depth advisory in
sales violations, suitability issues, and
complaints
Advisory
Areas
Central
Compliance
E-Comm Surveillance
Control Room / Conflicts
Management
Financial
Crime
Trade Surveillance
CRR & Reg
Reviews
Information Risk
Customer Complaints
Activity Volumes
Collect Data
Identifies KRIs that are above
thresholds / limits
Identifies relevant
alerts
!
Sorts compliance
findings by priority
Prioritize Issues
Use risk scorecards to
prioritize
Reporting
Communicate
Analytics Insights
Predict Issues Suggest Resolution Actions Identify Patterns
y1
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Use predictive analytics to
identify correlations, root
causes between issues
Use Machine Learning to learn from resolved
actions and false positives to:
• Auto adapt models for better prediction
• Suggest potential actions
Use advanced
visualization to
identify patterns
Financial Crime Issues
Non-Disciplinary Issues
(systems, procedures, training, …)
Disciplinary Issues
(Investigation, revocation, etc..…)
Closed cases
(False Positive)
Issues
Action
PlanAction
PlanAction
Plan
Issues
Action
PlanAction
PlanAction
Plan
Issues
Action
PlanAction
PlanAction
Plan
Investigate and
assign actions on
relevant cases
Insight / Prioritization Issues
(risk weight & model review)
Issues
Action
PlanAction
PlanAction
Plan
Feedback loop
Communicate and
report on the
various data
available issues,
risk, false positive,
resolutions

INVESTMENT IN TOOLS AND TECHNOLOGY
Most firms leverage multiple tools and products in their operational processes. End-to-end solutions can support conduct monitoring
and production of MI, while utilizing technology to provide reminders to help change staff behavior.
• It is unethical to
only monitor
inward facing
fraud
• A large portion of
customers are
unaware with the
lack of fiduciary
duty
Data Detection Reporting
• Accenture can help firms
establish preferred practices
within Data Management:
– Data Governance
– Data Quality
– Big Data Strategies
• There are both established
and start up providers, as well
as in-house built systems that
provide detection solutions.
• Accenture has relationships
and experience with these
solutions and can help
evaluate, implement and
improve these solutions
• Establishing a reporting
architecture based on critical
information that is verified and
reported in a timely manor is
key to a surveillance program
• Accenture can institute
leading practices in
surveillance management
information and management
reporting
• Robust and adaptive
investigations are critical to a
surveillance program
• Accenture can evaluate
investigation practices to:
– Establish robust analysis
across discrete systems
and data sets
– Establish feed back and
continual improvement
processes
– Reduce false alerts
Surveillance Monitoring
Investigation
Tools and Vendors
• NICE Actimize™
• Cafyne, Inc.
• Nexidia Inc.
• Verint Systems Inc
• Attivio, Inc.
• Fonetic
Solutions S.L.
• Actiance, Inc.
• Neurensic™
• Bloomberg
Vault ™
• SAS Institue Inc.
• Catelas, Inc
• ForcepointTM UEBA (formerly
Red Owl)
• SAP® BusinessObjects™
• TIBCO® Spotfire®
• Qlikview®
• Tableau®

Preparing for the Conduct Journey

WHOSE IS RESPONSIBLE FOR REPUTATIONAL AND CONDUCT RISK?
Mitigating Conduct and Reputational risk is a cross-organizational effort, requiring support from all stakeholders, and necessitating
close management of inter-dependencies across the lines of defense. This allows consistent delivery against roles and responsibilities
and mission critical use cases.
Operational
Risk
Internal
Audit
Finance
Human
Resources
Compliance
Vendor Risk
Management
Enterprise
Data Office
Product
Control
3rd Line of Defense
2nd Line of Defense
1st Line of Defense
Surveillance
Tools
Investigation
& Reporting
People
Governance,
Rules &
Standards
Our experience indicates that leading firms have defined a holistic reputational and conduct risk framework, with clearly defined leadership roles
and accountabilities so as to closely manage the inter-dependencies and help protect the firm’s ethical health and reputation.

PREPARING FOR THE JOURNEY
Industry responses vary according to three imperatives: response to Regulatory / Monitoring enquires (i.e. OSFI); remediation of
prior misconduct; or ramping up for future steady-state compliance.
Key Activities
Set values and strategy
Conduct risk assessment including product risk assessment
Review business model, strategy and operating model to deliver good
customer outcomes
Develop ethical data policy, procedures and processes
Develop customer communication process and procedures including review,
approval and testing
Define external complaint and internal whistleblowing case management
procedures aligned to regulatory expectations
Review governance structures and individual responsibilities
Develop remuneration policy aligned with business risks and good customer
outcomes
Upgrade surveillance tools
Develop conduct risk metrics (KPIs) as part of behavior report
Cross firm training and communications
Remediate marketing and sales practices
Phase
Principles and
Strategy
Diagnostics and
Evidencing
Analytics, Management
Information, Reporting
Process Monitoring and
Surveillance
Embedding Culture Change
Regulatory and Legal Remediation
Current progress
North American banks
Current progress
UK banks

Accenture Experience and Accelerators

ACCENTURE FINANCE & RISK
600+
Financial services
clients serviced
globally
Breadth and Depth of
Experience to Meet Your
Business Needs:
We help the world’s banks, insurance,
capital markets and FinTech firms meet
unparalleled strategic,
operational, technology
and sourcing demands.
Our goal is to be recognized as the
premier innovation and
execution partner in the
Financial services industry,
collaborating with client and eco-
system alliances and partners to
create sustainable value for
them and our communities.
We offer innovative solutions developed
jointly with key alliances such as
Microsoft Corporation, SAP SE, Oracle
Corporation, Cisco Systems, Inc and
Salesforce.com, Inc.
US$34.9
billion
In Annual Revenues
(2017)
449,000
Employees
40+
Industries Served
98 of top 100
Clients have worked with
Accenture for at least 10
years
120+
Clients served
across the globe
150+
Powerful alliance network
of market leaders and innovators
FINANCE & RISK
Serving leading
financial
services
clients in nearly
50 countries
5,000+
Finance & Risk
professionals
across the
globe
Fortune Global 500 companies we work with include
We help clients streamline
operating models, integrate
risk and finance functions,
align and integrate
disparate sources of data,
innovate to manage risk and
deliver technology solutions
FINANCIAL SERVICESACCENTURE
Cyber Risk &
Resilience
Finance &
Accounting
Sourcing &
Procurement
Regulatory &
Compliance
Financial Risk
Management
Finance &
Risk Analytics
Areas of Focus:
50,000+
Financial services
professionals globally

CONDUCT RISK OFFERING OVERVIEW
Accenture has outlined a set of conduct risk management services that can help financial institutions improve company culture, pre-
empt regulatory censure or differentiate their customer proposition.
Ethics, Conduct, and
Culture Assessment
Conduct Risk
Management Program
Culture
Transformation and
Remediation
Conduct Surveillance,
Reporting and Metrics
Strategic and
Reputational Risk
Assessment
Sales Practices and
Suitability Framework
Third-Party Conduct
Program
Organizational health check
analysis and benchmarking
against the conduct maturity
model across the three lines
of defense.
Gap analysis, design, and
implementation of Conduct
Risk Management
programs including
understanding regulatory
and non-regulatory
requirements across
business lines and control
partners.
Organizational and
behavioral transformation
across all three lines of
defense aligning people,
processes, and technology
to the organization’s
strategic objectives, values,
mission, and target culture.
Insights on breadth and
depth of risks, root causes,
acceptable measures, and
risk event outcomes.
Extensive KRI library and
customizable analytics
application for conduct
reporting metrics.
Firm level analysis to create
an industry relative
benchmark and help clients
define a roadmap for their
strategic and reputational
risk management policies,
procedures, and metrics
going forward.
Conduct independent
review analyzing sales
campaigns, performance
metrics and drivers,
governance structure and
controls, and other related
data to identify conduct
related issues and
recommend potential
solutions.
Governance model and
assessment capabilities to
measure, monitor, and
engage on third-party
conduct activities.
• Organization wide health
check (including survey)
analysis
• Risk data governance and
security assessment
• Assessment of the control
environment for operating
effectiveness
• Ethics program designed
in accordance with
Federal Sentencing
Guidelines
• Dodd-Frank Act section
956 incentive structure
review
• Setting global standards
and program support
• Operating model design
and alignment (policy
and process design,
whistleblowing)
• Process and technology
design and
implementation for
conduct management
• Leadership conduct
framework
• Trust-based leadership
development program
including programs for
designing and testing
desired cultural changes
• Remediation of past
events (misselling,
payment protection
insurance, etc.)
• Incentives training and
tools for analysis,
gamification and
simulations
• Employee engagement
reimagination
• Implementation of
conduct MI application
• KRI identification,
definition, and
prioritization
• Conduct risk dashboard
design and development
• End-to-end surveillance
(trading, e-comms, AML)
– systems and data
warehousing, algorithm
development
• Gap analysis for where
existing KRIs should be
enhanced and new ones
developed
• Strategic roadmap for
protecting against future
reputational risks
• Assessment of banking
sales metrics and
performance drivers
• Captive agency sales
model, practices, and
oversight design
• Direct to customer
insurance sales metrics
and performance
alignment
• Service level agreement
review and performance
analytics
• Vendor management
systems assessment and
reporting capabilities
DESCRIPTIONTYPICALENGAGEMENTS

SAMPLE OF AN ACCELERATOR:
CONDUCT CULTURE MATURITY MODEL
Many firms have started to transform their culture by addressing regulatory requirements and updating their value statements, but
the extent of change is hard to assess. Applying a firm’s practices to a maturity model permits a deeper understanding of how
embedded the behaviors, policies and practices are within the DNA of the firm and its employees.
3
No. Elements of Model Spectrum Description
1 Customer Centricity
To put the customer experience at the center of products and
transactions, delivering the best possible experience and
rebuilding consumer trust.
2 Product Governance
To align product development and marketing processes with
customer needs and to deliver true value for customers.
3 Compensation
To incentivize, reward and recognize ethical conduct in the
context of company performance.
4 Leadership
To visibly set tone, messages and behaviors and guide
transformation and operations.
5 Data Stewardship
To both protect customer data and incentivize usage for customer-
focused product development.
6 Values and Behaviors
To uphold and demonstrate at all levels and for all roles the firm’s
desired culture and ethics.
7 Communications
To articulate what is, and is not appropriate conduct, risk-based
decision making and progress made.
8 Training
To reinforce new knowledge, change mindsets, and discourage
risky behavior of staff.
9 Metrics
To establish clear performance indicators and measure change
required to transform.
2
Low Product Governance High Product Governance
1 3 4
Low Compensation High Compensation
1 2 4
3
Low Leadership Involvement High Leadership Involvement
1 2 4
2
Low Data Stewardship High Data Stewardship
1 3 4
2
Low Values and Behavior High Values and Behavior
1 3 4
3
Low Training High Training
1 2 4
2
Low Degree of Communications High Degree of Communications
1 3 4
Illustrative
Low Customer Centricity High Customer Centricity
2 3 41
2
Low Metrics High Metrics
1 3 4

SUSPECT BEHAVIOR DETECTOR SURVEILLANCE PLATFORM
The Suspect Behavior Detector Surveillance Platform demonstrates the power of deploying big data, advanced analytics and interactive
visualizations, leading to threat identification and prudent risk decision making. The tool deploys Surveillance Analytics, Social Network
Analysis, and Deep Emotion / Sentiment Analysis in the detection of misconduct and behavioral risk in financial sector.
Suspect Behavior Detector
(SBD) Surveillance Platform
Tracking
Track risk and surveillance
actions, converting insight into
prudent risk decisioning
Core Capabilities
Integration
Integrate multiple data sources to
produce a holistic surveillance
view
Analytics
Obtain insight into illicit behavior
through communication
surveillance and sentiment
extraction
Thought
Leadership
Embedded Accenture-Stevens
co-developed advanced analytics
AI assets and accelerators

METRICS INVENTORY
Experience in delivering MI solutions for operations and compliance risk management, and the emerging discipline of conduct /
human risk has enabled Accenture to maintain a database of over 600 common metrics.
Risk Category Example Metrics
Data
Deficiency in quality of
data or how it is used
Average time spent
extracting and cleaning
data vs. analysis
People
Violation of internal
policies by employees or
risks introduced by
customers
Personal trading
instances (one time
and repeat) without
pre-clearance
Process
Deficiency in an existing
procedure, or absence of
a procedure
Percent or number of
accounts without
proper due diligence
(i.e. KYC, OFAC, etc.)
System
Breakdowns in existing
systems or technology
Costliness of making
changes to existing
systems
People
Compliance issues and
risks resulting from
employee actions
Issue type quarterly
trend by product area
Programs
Metrics related to
programs used to
prevent compliance
issues
Total number of
breaches of the firm’s
Group AML Policy
identified during the
calendar month
Risk / Controls
How risks are handled
via controls
Percent of current
open audit items
owned by Compliance
function and closed
within the target
timeframe
Compliance Risk
Metrics to support compliance
risk management
Operations Risk
Metrics related to loss event
management – how well / poorly
losses are being managed or how
much they may increase as the result
of a changing risk metric
Conduct / Human Risk
Metrics to help quantify conduct risk
across three dimensions, in line with
emerging regulatory principles (e.g.,
Financial Conduct Authority)
Dimension Examples
Risk Pillars
Key sub-components
of conduct risk
Customer and Care;
Sales Process;
Product Design;
Misuse of Information;
Insider Dealing; and
Market Manipulation
Business Type
Type of business
lines being operated
Retail; Investment
Banking; Mortgage
Providers
Client Type
Type of client served Retail; Wholesale
Reputational Risk
Metrics to help quantify and gain
awareness around reputational risk
People
Employee conduct and
customers’ perception of
it
Exec Compensation;
Employee Compliance;
Employee Behavior
Customer
Customer feedback and
firm’s actions or inactions
Product Complaints;
Compromised
Customer Credentials
Regulatory
Difficulty keeping pace
with regulatory changes
Number of regulatory
events evaluated
within target timeframe
Business Conduct
Increasing corporate
social responsibilities
Presence of social
responsibility strategy
approved at senior
management level

EXAMPLES OF ACCENTURE THOUGHT LEADERSHIP
Accenture has developed a number of thought leadership point of views and approaches specifically focused on managing
reputational and conduct risk, assessing ethics and culture, and establishing surveillance and employee misconduct monitoring
programs to support clients in their efforts to be leaders in their field.
Protecting and Building Firm
Reputation: Addressing the
Conduct Challenge
The Ethics and Conduct
Challenge for US Banks:
Learning from the UK
Experience
The Digital Emperor Wears No
Clothes: Are Business Leaders
Ready for a World of Radical
Transparency?
Getting Surveillance Right:
Protecting Banks’ Reputation
and Profitability
Communications Surveillance:
Identifying and Preventing
Misconduct in Digital
Communications

CONTACTS
Samantha Regan
Accenture Finance & Risk Managing Director,
Global Regulatory and Compliance Lead
samantha.regan@accenture.com
Bailey Hansford
Accenture Finance & Risk Senior Manager,
NA Conduct Risk & Consumer Protection Lead
bailey.hansford@accenture.com
Usman Raj
Accenture Finance & Risk Senior Manager,
Canadian Risk and Compliance Lead
usman.raj@accenture.com
Dennis Chan
Accenture Finance & Risk Consultant
dennis.c.chan@accenture.com

ADDRESSING SALES PRACTICE AND CONDUCT RISK
IN THE CANADIAN MARKET
About Accenture
Accenture is a leading global professional services
company, providing a broad range of services and
solutions in strategy, consulting, digital, technology
and operations. Combining unmatched experience
and specialized skills across more than 40
industries and all business functions—underpinned
by the world’s largest delivery network—Accenture
works at the intersection of business and
technology to help clients improve their
performance and create sustainable value for their
stakeholders. With more than 449,000 people
serving clients in more than 120 countries,
Accenture drives innovation to improve the way the
world works and lives. Visit us at
www.accenture.com
Accenture, its logo, and High Performance
Delivered are trademarks of Accenture.
Disclaimer
This presentation is intended for general
informational purposes only and does not
take into account the reader’s specific
circumstances, and may not reflect the
most current developments. Accenture
disclaims, to the fullest extent permitted
by applicable law, any and all liability for
the accuracy and completeness of the
information in this presentation and for
any acts or omissions made based on
such information. Accenture does not
provide legal, regulatory, audit, or tax
advice. Readers are responsible for
obtaining such advice from their own legal
counsel or other licensed professionals.

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